Except for crimes of passion, it's doubtful that even semiprofessional criminals would plan a crime using a smartphone unless it was encrypted, because it's just too simple to do. But criminals do make errors in their security discipline that help law enforcement cyber pros catch them. Ross Ulbricht, the infamous Dread Pirate Roberts who allegedly founded the Silk Road marketplace for illegal goods and services, drew the FBI’s attention to himself by soliciting for developers on a Bitcoin community board using his personal email address. FBI Chief James Comey must be hoping to keep his options open to capture those criminals who break with security disciplines and overlook encrypting their smartphones.

Criminals, the paranoid, and those who value their personal privacy don’t have to wait for the Android L to encrypt their Android devices. If the device doesn't have a PIN code or password, one can be set using the Android settings menu. The longer the PIN or password, the better.

Important: Some Android devices, such as the Galaxy S4, can be decrypted. Others, such as the Moto X, require a factory reset to remove encryption.